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Christopher Stagg Comments on the U.S. Munitions List and the DDTC's Suspension on Capacitor Export Controls in Export Compliance Manager

"DDTC Amends Capacitor Export Controls"

Export Compliance Manager

Christopher Stagg comments in Export Compliance ManagerĀ on how the U.S. government has not updated sections of the U.S. Munitions List (USML), part of the International Traffic in Arms Regulations (ITAR), in over a decade, and how the Defense Trade Controls (DDTC) recently used its powers to temporarily suspend some of the controls on certain capacitors when incorporated into non-ITAR items, because such capacitors are now widely used in civilian items such as Wi-Fi routers. "It has been nearly a decade since Category XI has been revised, and this development shows how dual-use applications are being increasingly captured on the U.S. Munitions List, given that the category has not been revised for some time," Stagg said, adding that "[i]t should serve the need for DDTC to move more expeditiously in 2023 on reviewing the USML for other such issues, which should give the public the ability to provide input through proposed and interim final rulemaking, thereby having an opportunity to influence what moves off the USML or by receiving clarification of existing language that could have the same effect of moving items from the USML."